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NEWINGTON, CT, August 10, 2005--Italy is reported to be the latest country added to the list of those that no longer require Amateur Radio applicants to have passed a Morse code examination to gain HF access. The Daily DX reported this week that current IW-prefix "no-code" VHF/UHF licensees in Italy now will be allowed operate on HF and may also apply for new call signs if they wish. Canada eliminated Morse code as the "sole additional requirement" for HF access in late July. To date, more than two dozen countries around the world--including such major players as the United Kingdom, Germany, Australia and New Zealand--no longer require Amateur Radio applicants to pass a Morse code examination to operate on frequencies below 30 MHz. If the FCC's past observations on the subject are any clue, the US could be joining the no-code-required club in the future.
"We believe that an individual's ability to demonstrate increased Morse code proficiency is not necessarily indicative of that individual's ability to contribute to the advancement of the radio art," the FCC maintained in its December 1999 Amateur Radio restructuring Report and Order (R&O). "As a result, we find that such a license qualification rule is not in furtherance of the purpose of the amateur service, and we do not believe that it continues to serve a regulatory purpose."
The Commission in 1999 went on to say that it was retaining
a minimal 5 WPM Morse requirement for all license classes only because of the
treaty obligation then in place requiring a demonstration of Morse ability for
HF access. It declined, however, to order the Morse requirement to sunset if
World Radiocommunication Conference 2003 (WRC-03) decided to drop the treaty
obligation regarding Morse code.
WRC-03 delegates revised Article 25.5 of the international Radio Regulations, letting countries determine for themselves "whether or not a person seeking a license to operate an amateur station shall demonstrate the ability to send and receive texts in Morse code signals." While demonstrating Morse code ability no longer is an international obligation, countries may elect to continue requiring Amateur Radio applicants to pass a Morse code examination.
The Past as Prologue?
In its Notice of Proposed Rule Making and Order (NPRM&O) in WT Docket 05-235, released July 19, 2005, the FCC proposed to eliminate the 5 WPM telegraphy examination altogether. At the same time, it dismissed petitions calling for--among other things--a new entry-level license with HF privileges.
In wording that closely mirrored remarks in its 1999 restructuring R&O, the Commission said its review of the 18 petitions and comments in the proceeding showed that "the majority agree" with its 1999 stance on the Morse requirement. "We believe that because the international requirement for telegraphy proficiency has been eliminated," the FCC asserted, "we should treat Morse code telegraphy as a communications technique with the same standing as other modulation techniques in the Amateur Service licensing requirements." The FCC further said it was not persuaded by the ARRL's petition request to retain the 5 WPM Morse requirement solely for Amateur Extra applicants.
But perhaps recalling what it also said in 1999--that few issues coming before the Commission "present such a clear dichotomy of viewpoints" as Morse code--the FCC stopped short in the current proceeding of making the Morse requirement disappear. Instead, it invited another round of comments on the subject.
The US Amateur Radio community has taken up the Commission's offer in large numbers and with great enthusiasm. As of mid-week, more than 1300 comments--nearly four times the number of just a week earlier--had been posted via the FCC's Electronic Comment Filing System (ECFS). The majority focused solely on the FCC's proposal to drop the Morse code requirement altogether. While most tend to file brief "yea" or "nay" comments, many postings reflect the deeply emotional nature of the continuing Morse code debate.
Opinions Remain Divided
Those favoring the Morse requirement frequently suggest that dropping it altogether will lead to a overall decline in the skill and dedication of new operators. Others cite Morse as a longstanding tradition that ought not be cast aside lightly, and a few cite its potential in emergency communication. The FCC already dismissed such arguments in 1999.
"To the extent that these commenters put forth arguments premised on personal preference or concerns regarding on-the-air etiquette amongst Amateur Radio operators, we reiterate pronouncements made in the Codeless Technician Decision," the FCC said five years ago. In that decision, which led to the creation of the first code-test-free US ham ticket, the Commission stated that passing a telegraphy examination for regulatory purposes "is no more and no less than proof of the examinee's ability to send and receive text in Morse code at some specified rate."
Those endorsing its elimination often assert that Morse is largely irrelevant today and that retaining the requirement is keeping a lot of people from pursuing Amateur Radio. Several commenters also have contended that Morse code should rise or fall on its own now, not be mandated for licensure. These are arguments the FCC essentially agreed with in 1999 and again in 2005.
"We are not persuaded that it is in the public interest to require examinees to demonstrate an ability to exchange messages in one particular communications technology when the Amateur Service rules do not require operators to use this technology and when the trend in amateur communications is to use voice and digital technologies," the FCC said in its NPRM&O in WT Docket 05-235.
Generally speaking, the Commission has been disinclined to revisit what it considers once-trod ground.
IARU Already on Record Supporting Removal
Following WRC-03, the International Amateur Radio Union (IARU) Administrative Council called for the removal of Morse code as an examination requirement to operate on HF. The Council reiterated its position, first taken in 2001, that Morse code proficiency "as a qualifying criterion for an HF amateur license is no longer relevant to the healthy future of amateur Radio."
"IARU policy is to support the removal of Morse code testing as a requirement for an amateur license to operate on frequencies below 30 MHz," the IARU Administrative Council resolved. At the same time, the council's resolution recognized Morse code as "an effective and efficient mode of communication used by many thousands of radio amateurs."
Switzerland, UK Lead Move to Drop Morse Requirement
In the wake of WRC-03, Switzerland became the first country to announce it was eliminating Morse code as a requirement for HF access. It was followed in short order by the United Kingdom.
In addition to Italy, Canada, Switzerland, the United
Kingdom, Germany, Australia and New Zealand, the list of countries that have
dropped Morse code as a requirement includes the Czech Republic, Spain, South
Africa, Iceland, Sweden, Austria, Belgium, Bulgaria, Denmark, Finland, France, Ireland,
Kenya, Luxembourg (provisional CEPT Class 2 HF access), The Netherlands, Norway,
Poland (limited), South Africa, Hong Kong, Papua New Guinea and Singapore.
Filing Comments on WT Docket 05-235
To file on-line comments on the FCC NPRM&O in WT Docket 05-235 or to view others' comments in the proceeding, visit the FCC Electronic Comment Filing System (ECFS) site and click on "Submit a Filing" or "Search for Filed Comments."
In either case, type "05-235" in the "Proceeding" field, being careful to include the hyphen but not the quotation marks. Directions for filing comments, which can be in the form of an attached document, are on the ECFS site. Click on "Getting Started" to learn more.
The FCC is not expected to
release a Report and Order in WT Docket 05-235 until late this year at
the soonest.